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CMS Proposes New Limitations to the Isolated Transactions Exception to the Stark Law

The Situation: The isolated transactions exception under the Stark Law has been used by some providers and entities to retroactively protect services arrangements that do not qualify for personal services or market value...more

OIG Proposes Modifications to Personal Services Safe Harbor Under the AKS

The Situation: The Office of Inspector General ("OIG") proposes modifications to the personal services and management contracts safe harbor of the federal Anti-Kickback Statute ("AKS"). These modifications expand shelter to...more

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